Document pB4vvNn8rrNe3Nj1de62QdQRD

May 29, 1977 Chemical Division PPG Industries Ref: Paragraph (K) Medical Surveillance 1910.39Q Vinyl Chloride OSHA. See attachment #1 The above reference details the minimum requirements that will be implemented in all PPG operations for employees working in VCM operations and exposed to VCM in air concentrations at or above the "Action Level". I. Pre-Placement Examination - All employees prior to being assigned to a job which will potentially expose them to VCM will be provided an initial medical examination in accordance with the above reference. ' If ari employee's health would be materially impaired by exposure to VCM, he Will not be assigned to a job which will potentially depose him to VCM. The Plant Physician will certify as to the suitability of an employee to work in a job potentially exposing him to VCM and to wear protective equipment and respirators, utilizing the form shown in attachment #2. A copy of this form will be provided to the anployee, a copy will be placed in the employee's plant medical record and other copies provided to appropriate management personnel. II. Periodic Examination * All employees working on a job which potentially exposes them to VcM vrt.ll be provided medical examinations in accordance with the above reference at either 6 (six) or 12 (twelve) month intervals. If in the Physician's judgement the employee's health would be materially impaired by exposure to VtiM, he will be'removed from such potential exposure. The Plant Physician wall certify as to the employee's suitability as described above. III. Emergency (Massive release of VCM) - Any employee involved in same wall be seen by the Plant Rhysician as soon as possible. 0. Abnormal Liver Function lests - if any of the 5 tests on the employees serum ' specimen required in the above reference are significantly abnormal, the employee will be evaluated in the Plant Medical Department and advised of the necessity to repeat the abnormal test or tests within 2 (two) or 3 (three) weeks prior to which time he should avoid such activities as might be expected to cause a test to be abnormal. Plant management should be advised as to the necessity to repeat the abnormal tests at the time employee is advised. If the repeat tests o^ tests are significantly abnormal, the Plant Physician may certify as to the unsuitability of the employee to continue working in a > job potentially exposing him to VCM. The Plant Physician may arrange for a 'more comprehensive examination of the employee with appropriate medical specialists if he believes this is clinically indicated. Such examinations may include but not be limited necessarily to the following special procedures when indicated; liver scanning, liver angiogram, liver biopsy. V. Return of an Employee to Potential VCM Exposure - If in the Plant Physician's opinion, an employee who has been removed from potential VCM exposure for health reasons has sufficiently recovered so that VCM exposure would not materially impair the employee's health, the Plant Physician may so certify as described above. 1- - SL 072883 VI. Contractor Employees ^ Such employees' medical surveillance will be as described above and under the direction of the Plant Physician. rvih Former PPG Employees Followup - All employees who have had 5 (five) or V__J more years employment at PPG in a job where they were potentially exposed ri to VCM will be followed up as follows: l^\) '1. At the time that they leave PPG they will be advised as to the advisability JLf followup examinations every 3 (three) years to include the 5 tests on a serum specimen required for VCM employees under the OSHA Standard V and that PPG will pay for such tests if they provide us with a ^ permanent address. 2. PPG will send them a notice every 3 (three) years advising than as to the arrangements for the tests and then advise them as to the results. 3. PPG will request death certificates when a employee or former employee dies. 4. Appropriate epidemiological analysis will be performed on the followup data received. Note: Although not required by the above referenced OSHA Standard, because _ K presently available medical evidence suggest involvement of other organ systems of the body is possible, the following additional tests may be considered on an annual basis: 84A. 12 CBC Urine Fvc & Fevl Chest xray Any abnormalities should be considered as a basis for possible rejection on the preplacement exam and appropriate followup on the peiodic exam. SL 072884 *t OCCUPATIONAL HEALTH ATTACHMENT #1 S-B6 31 '.5344A (5) (i) Entry Into unkown concentra (iii) The purpose :`o.\ proper use, and limi promptly after any examination. A copy tions or concentrations greater than tations of respirator} protective devices; of the physician's statement shall be pro 36.000 ppm (lower explosive limit) may be made only for purposes of life rescue; and (ii) Entry Into concentrations of less (Section 1910 93q 0) amended at 39 FR 41848, December 3. 1974] (lv) The fire hazard and acute toxic ity of vinyl chloride, and the necessary vided each employee.V" (5) If any employee's health would be materially impaired by continued ex than 36,000 ppm, but greater than 3,600 protective steps; posure, such employee shall be with ppm may be made only for purposes of (v) The purpose for and a description drawn from possible contact with vinyl life rescue, firefighting.' or securing equipment so as to prevent a greater hazard from release of vinyl chloride. of the monitoring program; (vi) The purpose for, and a descrip chloride. (6) Laboratory analyses for all bio logical specimens included in medical (6) Where air-purifying respirators tion of, the medical surveillance examinations shall be performed in labo are used: (1) Air-purifying cannlsters or car tridges shall be replaced prior to the expiration of their service life or the end of the shift in which they are first used, whichever occurs first, and (ii) A continuous monitoring and alarm system shall be provided where concentrations of vinyl chloride could reasonably exceed the allowable concen trations for the devices In use. Such sys tem shall be used to alert employees when vinyl chloride concentrations exceed the allowable concentrations for the devices In use. (7) Apparatus prescribed for higher concentrations may be used for any lower concentration. (h) Hazardous operatione. (1) Em ployees engaged In hazardous operations, including entry of vessels to clean poly program; (vii) Emergency procedures: (viii) Specific information to aid the employee in recognition of conditions which may result in the release of vinyl chloride; and (ix) A review of this standard at the employee's first training and indoctrina tion program, and (annually thereafter. (2) AU materials" relating to the pro gram shall be provided upon request to the Assistant Secretary and the Director. (k> Medical surseOiance. A program of medical surveillance shall be insti tuted for each employee exposed, with out regard to the use of respirators, to vinyl level. such ecTmhhpleoloriypdereoegiwrnaimthexcsaehnsas1ol1l nopnofir-oonthvrvtieiudrfen*aitcepvtaoifocorhnh- examinations and tests in accordance with this paragraph. All aminations and procedures medical shall be pee'r / ratories licensed under 42 CFR Part 74. (7) If the examining physician deter mines that alternative medical examina tions to those required by paragraph' (k)(l) of this section will provide at least equal assurance of detecting med ical conditions pertinent to the exposure \ to vinyl chloride, the employer may ac cept such alternative examinations as meeting the requirements of paragraph (k) (1) of this section, if the employer obtains a statement from the examining physician setting forth the alternative examinations and the rationale for sub stitution. This statement shall be avail- I able upon request for examination and] copying to authorized representatives oil theAslfjfant^retare and the Direct,nr /. ^r<rTslgns and labels. (1) Entrances to regulated areas shall be posted with leg- ible signs bearing the legend; vinyl chloride residue from vessel walls, formed by or under the supervision of a shall be provided and required to wear licensed physician, and shall be provided CAHCEa-&T7St>ECT AGEIfT, AeEA Authorized Personnel Only and use; i without cost to the employee, Section 1910.93q (1) (1) amended at 39 FR (1) Respiratory protection In accord (1) At the time of initial assignment, 1848, December 3, 1974) ance with paragraphs (c) and (g) of or upon institution of medical surveil (2) Areas containing hazardous ojSe?- this section; and / lance; ations or where an emergency currently (ii) Protective garments to prevent (i) A--general physical examination exists shall be posted with legible signs skin contact with liquid vinyl chloride or shall be performed, with specific atten bearing the legend; with polyvinyl chloride residue from tion to detecting enlargement pf liver, C.vncer-Suspect Agent in aher vessel walls. The protective garments shall be selected for the operation and Its possible exposure conditions. (2) Protective garments shall be pro spleen or kidneys, or dysfunction in these organs, and for abnormalties in skin.,' connective tissues and the pulmonary system (See Appendix A). Protective Equipment Required Authorized Personnel Only [Section I910.93q (1) (2) amended at 39 FR 41848, December 3, 1974] vided clean and dry for each use. (ii) A medical history shall be taken, (3) Containers of polyvinyl chloride (i) Emergency situations. A written including the following topics; Tesin waste from reactors or other waste operational plan for emergency situa (A) Alcohol intake; contaminated with vinyl chloride shall tions shall be developed for each facility \oi rub* Umsul;oryij oa#mcpar'.ris , be legibly labeled: storing, handling, or otherwise using (C) Work history and past exposurei CONTAMINATED WITH vinyl chloride as a liquid or compressed to potential hepatotoxic agents, includ Vinyl Chloride gas. Appropriate portions of the plan ing drugs and chemicals; Cancer-Suspect Agent shall be implemented in the event of an (D) Past history of blood transfu- iS_ection 1910.93q (1) (3) amended at 39 emergency. The plan shall specifically sions; and FR 41848, December 3, 1974J provide that: (E) Past history of hospitalizations.7 (4) Containers of polyvinyl chloride (1) Employees engaged in hazardous (iii) A serum specimen shall be ob shall be legibly labeled; operations or correcting situations of ex isting hazardous releases shall be equipped as required in paragraph (h) of this section; tained and determinations made of: (A) Total bilirujain; ;B) Alkaline phosphatase; (C) Serum glutamic oxalacetic trans Folyvintl Chloride (or Trade Name) Contains Vinyl Chloride Vinyl Chloride is a Cancer-Suspect Agent (2) Other employees not so equipped shall evacuate the area and not return until conditions are controlled by the aminase (SCOT); (D) Serum glutamic pyruvic transam inase (SGPT); and (5) Containers of vinyl chloride shall be legibly labeled either: methods required In paragraph (f) of this section and the emergency Is abated. (j) Training. Each employee engaged In vinyl chloride or polyvinyl chloride operations shall be provided training in a program relating to the hazards of (2) Gamm3 giustamyl transpeptidase." (1) (2) Examinations provided in accord ance with this paragraph shall be per formed at least: (i) Every 6 months for each employee who has been employed in vinyl chlo Vinyl Chloride Extremely Flammable Gas Under Pressure Cancer-Suspect Agent or (ii) In accordance with 49 CFR Parts 170-189, with the additional legend: vinyl chloride and precautions for its ride or polyvinyl chloride manufacturing Cancer-Suspect Agent safe use. for 10 years or longer; and applied near the label or placard. (1) The program shall include'.' (ii) Annually for all other employees. [Section 1910.93q 0) (5) (ii) amended at 39 (i) The nature of the health hazard from chronic exposure to vinyl chloride including specifically the carcinogenic hazard; (3) Each employee exposed to_ an FR 41848, December 3, 1974] emergency shall be afforded appropriate (6) No statement shall appear on or medical surveillance. near any required sign, label or instruc (4) A statement of each employee's tion which contradicts or detracts irom (ii) The specific nature of operations suitability for continued exposure-^to the effect of, any required warning, which could result In exposure to vinyl vinyl chloride including use of protec"2~~lnfqrmation or instruction, chloride in excess of the permissible tive equipment and respirators, shall be (m) Records. (1) All records main- limit and necessary protective steps; obtained from the examining physician tained in. accordance with this section 4 10-75 Copyright Q 1975 by Th* 3ursou of Notional Affairs, [Sec. 1910fi3q|m)(1H 11 SL 072885 INDUSTRIES PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 LAKE CHARLES. LA. 70601 ATTACHMENT # 2 HEALTH CERTIFICATE _________________ ________ ______________ , Dept. , Badge ^ has been examined on______ m as a part of physical and is hereby (approved--conditionally approved--disapproved) for: 1. Continued work in the Vinyl Chloride/Organics Area for one year. 2. Use of respirators of any kind. 3. Use of protective equipment. Based on medical and laboratory examination--provided clinical findings do not change during this time. REASONS FOR DISAPPROVAL: H. B. Love joy, M. D. Plant Physician SL 072886